Technical Instruction for Obligors Submitting Prescribed Information to the Official Register of Prescribed Information and the Croatian Financial Services Supervisory Agency

1 Based on Article 15(7) of the Act on the Croatian Financial Services Supervisory Agency (Official Gazette nos. 140/05 and 12/12), in conjunction with Article 497(4) and Article 498(6) of the Capital Markets Act (Official Gazette nos. 65/18, 17/20, 83/21 and 151/22), the Croatian Financial Services Supervisory Agency, at its Management Board meeting held on 25 January 2023, adopts the TECHNICAL INSTRUCTION FOR OBLIGORS SUBMITTING PRESCRIBED INFORMATION TO THE OFFICIAL REGISTER OF PRESCRIBED INFORMATION AND THE CROATIAN FINANCIAL SERVICES SUPERVISORY AGENCY

1. INTRODUCTION This Technical Instruction for obligors submitting prescribed information to the Official Register of Prescribed Information and the Croatian Financial Services Supervisory Agency (hereinafter: Technical Instruction) contains a description of signing with a qualified electronic signature, as well as registration, access, login, and operational methods for authorized persons accessing the reporting system of the Croatian Financial Services Supervisory Agency (hereinafter: Hanfa) in the system for submitting prescribed information to the Official Register of Prescribed Information (hereinafter: SRPI) and in Hanfa's reporting system electronically with a qualified electronic signature. This Technical Instruction applies to issuers who submit prescribed and other information to Hanfa and SRPI, such as the list of related persons, compliance questionnaire, and governance practices questionnaire.
2. TECHNICAL PREREQUISITES FOR OPERATING IN HANFA'S REPORTING SYSTEM 2.1. Prerequisites for Signing with a Qualified Electronic Signature A qualified electronic signature is an electronic signature as defined by Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic identification and trust services for electronic transactions in the internal market (OJ L 257/73, 28. 8. 2014). To sign with a qualified electronic signature, the issuer must possess a crypto device (i.e., appropriate media issued by an authorized certificate issuer) containing two digital certificates: a) authentication certificate, and b) qualified electronic signature certificate. When signing with a qualified electronic signature, the issuer is obliged to use the option for separate storage of the original document from the file containing the qualified electronic signature. For detailed instructions on operating the electronic signing system, the issuer must contact the authorized certificate issuer (a legal entity authorized to issue digital certificates). 2.2. Prerequisites for Registration and Submission to Hanfa's Reporting System To successfully use Hanfa's reporting system, the issuer must meet the following prerequisites: a) hold an authentication certificate issued by the Financial Agency (hereinafter: FINA) b) install required components according to FINA's instructions c) have a computer with Internet access d) be registered in Hanfa's reporting system as a user 2 e) submit to Hanfa an authorization letter for the authorized person (user) of the Applicant. Upon receiving the USB stick with the digital certificate, the user must register their digital certificate using the appropriate interface on Hanfa's website. Users whose valid certificates are already registered in Hanfa do not need to re-register them. To obtain authorization for submitting specific types of information to Hanfa's reporting system, obligors must submit a completed authorization letter forming Appendix I of this Technical Instruction, the form of which can be downloaded from Hanfa's website. After successful registration of the authorized person (user) and upon receipt of a properly completed authorization letter for the authorized person (user), Hanfa will add the authorized person to the user registry and assign them the necessary rights for submitting data to Hanfa's reporting system. 2.3. Login to the User Registration Interface Launch your Internet browser and open Hanfa's website: https://www.hanfa.hr. In the menu on the right side, click "reports.hanfa.hr". 3 Insert the USB stick into your computer and click "Registracija" (Register) on the top right. 4 To log in to the system, first select the certificate you wish to use. Mark your desired certificate and confirm it by clicking "OK". After selecting the certificate, you must enter the PIN for accessing the cryptographic device (USB stick) containing your certificate. Enter the PIN and confirm by clicking "OK". 5 If you are already a registered user, the following message will appear on the user interface: If you are not a registered user, fill out the form and select the "Registriraj" (Register) action. 6 After successful registration, you will receive the following notification: 7
3. METHOD OF DATA SUBMISSION TO HANFA'S REPORTING SYSTEM 3.1. Prerequisites for Operation Before logging into Hanfa's reporting system, the issuer (user) must:

• be registered (complete the procedure described in section 2.3 of this Technical Instruction) and
• submit the appropriate authorization letter. 3.2. Login to the Data Submission Interface Launch your Internet browser and open Hanfa's website: https://www.hanfa.hr. In the menu on the right side, click "reports.hanfa.hr". 8 3.3. Data Entry into Hanfa's Reporting System You are at the entrance to Hanfa's electronic data submission interface. Insert the USB stick into your computer and select the "Prijava" (Login) tab from the menu on the right. 9 To log in to the system, first select the certificate you wish to use and confirm your selection by clicking "OK". After selecting the certificate, enter the PIN for accessing the cryptographic device (USB stick) containing your certificate. Enter the PIN and confirm by clicking "OK". 10 In case of unsuccessful login, the following message appears: After successful login, the initial user interface is displayed. 11 On the left side of the menu, "Predaja izvješća" (Submission of Reports) is located. When this link is selected, the types of reports for which you have authorization to submit to Hanfa's reporting system open. Select SRPI when submitting prescribed and/or other information submitted to SRPI only in PDF format. Select SRPI-G when submitting the annual report, which is submitted to SRPI in PDF and XLS format. Select SRPI-G-ESEF when submitting the annual report, which is submitted to SRPI in a single electronic reporting format (ESEF) as a ZIP file. Select SRPI-P when submitting the semi-annual report, which is submitted to SRPI in PDF and XLS format, and select SRPI-K when submitting the quarterly report, which is submitted to SRPI in PDF and XLS format. Select GFI-IZD-POD, GFI-IZD-KI, TFI-IZD-POD, TFI-IZD-KI, TFI-IZD-AIF, TFI-IZD-OSIG, TFI-IZD-ZSE, PFI-IZD-POD, PFI-IZD-KI, PFI-IZD-OSIG or PFI-IZD-ZSE when submitting financial reports, which are submitted to Hanfa's reporting system in XML format (NOTE: for submission in XML format, you may use the prescribed forms in XLS format). ➢ When submitting semi-annual and/or quarterly reports, submit them first in XML format because this submission includes a validation check, and only after receiving confirmation of successful XML submission submit them in PDF and XLS formats. Select GIKU-UOU-DION, GIKU-UOP-DION or GIKU-UOP-OBV when submitting the compliance questionnaire for share issuers and the governance practices questionnaire for share/bond issuers, which are submitted to Hanfa's reporting system in XML format (NOTE: for submission in XML format, you may use the prescribed forms in XLS format). Select PUO when submitting the list of related persons, which is submitted to Hanfa's reporting system in XML format (NOTE: for submission in XML format, you may use the prescribed forms in XLS format). 12 3.3.1. Report: SRPI If you have selected the SRPI report, this view will appear. Here you submit prescribed and other information submitted to SRPI only in PDF format. 13 Select the subject for which you are submitting the report: Select the category: 14 Select the language: 15 In "PDF file" click "Odaberi datoteku" / "Browse" (depending on the browser language Chrome/Internet Explorer). Then select the file stored on your computer that you intend to submit to Hanfa's reporting system in PDF format. Enter the file name. Repeat the procedure for "Potpis" (Signature). Finally, click "Predaj" (Submit) and the file will be submitted. 16 3.3.2. Reports: SRPI-G, SRPI-P and SRPI-K If you have selected one of these reports, this view will appear: Here you submit annual (in SRPI-G), semi-annual (in SRPI-P) and quarterly (in SRPI-K) reports from issuers in PDF and XLS files. Both files (PDF and XLS) for the same report must be submitted to the same SRPI report so that Hanfa's reporting system accepts them as a corresponding SRPI report. 17 Select the subject for which you are submitting the report: Select the year for which you are submitting the report: 18 Select the language in which you submit the report: Select whether the report is audited: 19 Select whether the report is consolidated: Select whether the subject is a share issuer: 20 Select whether the subject is a debt securities issuer: Select the NKD code: 21 In "PDF file" click "Odaberi datoteku" / "Browse" (depending on the browser language Chrome/Internet Explorer). Then select the file stored on your computer that you intend to submit to Hanfa's reporting system in PDF format. Enter the file name. Repeat the procedure for "Potpis" (Signature). After that, in "XLS file" click "Odaberi datoteku" / "Browse" (depending on the browser language Chrome/Internet Explorer). Then select the file stored on your computer that you intend to submit to Hanfa's reporting system in XLS format. Enter the file name. Repeat the procedure for "Potpis" (Signature). Finally, click "Predaj" (Submit) and the files will be submitted. 22 After the file is submitted, it becomes visible through SRPI. 23 3.3.3. Report: SRPI-G-ESEF When an issuer submits the annual report in ESEF, during submission they select as shown: Select the subject for which you are submitting the report: 24 Select the year for which you are submitting the report: Select the language in which you submit the report: 25 Select whether the report is audited: Select whether the report is consolidated: 26 Select whether the subject is a share issuer: Select whether the subject is a debt securities issuer: 27 Select the NKD code: When submitting the file, you must click "Odaberi datoteku" / "Browse" (depending on the browser language Chrome/Internet Explorer) and select the .zip file to be submitted. Enter the file name. Repeat the procedure for Potpis (Signature). Finally, click "Predaj" (Submit) and the file will be submitted. 28 After the file is submitted, it becomes visible through SRPI. The image below shows an example of a submitted ESEF for consolidated and non-consolidated reports. 29 3.3.4. Reports: GFI-IZD-POD, GFI-IZD-KI, TFI-IZD-POD, TFI-IZD-KI, TFI-IZD-AIF, TFI-IZD- OSIG, TFI-IZD-ZSE, PFI-IZD-POD, PFI-IZD-KI, PFI-IZD-OSIG, PFI-IZD-ZSE If you have selected one of these reports, this view will appear: Here you submit reports to Hanfa's reporting system in XML format using XLS forms. NOTE: Issuers may use XLS format forms to create XML files, guided by the instructions for creating an XML scheme from an XLS file available on Hanfa's website. 30 Select the subject for which you are submitting the report: Select the year for which you are submitting the report: 31 Select the quarter for which you are submitting the report: In "XML file" click "Odaberi datoteku" / "Browse" (depending on the browser language Chrome/Internet Explorer). Then select the file stored on your computer that you intend to submit to Hanfa's reporting system in XML format. Enter the file name. Repeat the procedure for "Potpis" (Signature). Finally, click "Predaj" (Submit) and the file will be submitted. 32 3.3.5. Reports: GIKU-UOU-DION, GIKU-UOP-DION, GIKU-UOP-OBV If you have selected one of these reports, this view will appear: Here you submit reports to Hanfa's reporting system in XML format using XLS forms. NOTE: Issuers may use XLS format forms to create XML files, guided by the instructions for creating an XML scheme from an XLS file available on Hanfa's website. 33 Select the subject for which you are submitting the report: Select the year for which you are submitting the report: 34 In "XML report" click "Odaberi datoteku" / "Browse" (depending on the browser language Chrome/Internet Explorer). Then select the file stored on your computer that you intend to submit to Hanfa's reporting system in XML format. Enter the file name. Repeat the procedure for "Potpis" (Signature). Finally, click "Predaj" (Submit) and the file will be submitted. 35 3.3.6. Reports: PUO If you have selected this report, this view will appear: Here you submit reports to Hanfa's reporting system in XML format using XLS forms. NOTE: Issuers may use XLS format forms to create XML files, guided by the instructions for creating an XML scheme from an XLS file available on Hanfa's website. 36 Select the subject for which you are submitting the report: Select the period for which you are submitting the report: 37 In "XML report" click "Odaberi datoteku" / "Browse" (depending on the browser language Chrome/Internet Explorer). Then select the file stored on your computer that you intend to submit to Hanfa's reporting system in XML format. Enter the file name. Repeat the procedure for "Potpis" (Signature). Finally, click "Predaj" (Submit) and the file will be submitted. 38 3.3.7. Downloading Confirmation You will receive confirmation of successful submission by clicking "Potvrde" (Confirmations) on the left menu. Click the (PDF) icon next to your desired report to download the confirmation. 39 The confirmation is prepared in PDF format and looks as follows (example): 40

4. TRANSITIONAL AND FINAL PROVISIONS This Technical Instruction enters into force upon the entry into force of the Regulation on Content, Form and Method of Submitting Prescribed Information to the Croatian Financial Services Supervisory Agency and in the Official Register of Prescribed Information dated 25 January 2023 (KLASA: 011-01/23-01/05, URBROJ: 326-01-70-72-23-3) and will be published on Hanfa's website. The provisions of this Technical Instruction regarding signing with a qualified electronic signature begin to apply from 1 April 2023. Until 31 March 2023, issuers may use advanced electronic signature in addition to qualified electronic signature. Upon entry into force of this Technical Instruction, the Technical Instruction for obligors submitting prescribed information to the Official Register of Prescribed Information and the Croatian Financial Services Supervisory Agency dated 27 January 2021 (KLASA: 011-02/21-01/02, URBROJ: 326-01-60-62-21-1) ceases to apply. KLASA: 011-01/23-01/06 URBROJ: 326-01-60-62-23-1 Zagreb, 25 January 2023. CHAIRMAN OF THE MANAGEMENT BOARD dr. sc. Ante Žigman 41 Appendix I. AUTHORIZATION LETTER for using the information submission system in the Official Register of Prescribed Information and in the reporting system of the Croatian Financial Services Supervisory Agency
5. Data on the business entity (issuer) – obligor for submitting prescribed information

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name of the entity (issuer)

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seat and address of the entity (issuer)

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OIB contact phone number 2. Data on the authorized person designated for submitting prescribed information

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name and surname ID number

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signature of the authorized person for representing the entity (issuer) M.P. In ____, dated ____